Mentality of tax evasion, non-cooperation for 20 years, wilful default. Compounding rejected as belated after conviction. Paying dues /= compounding.

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....Appellant's conduct showed mentality of evading taxes, not cooperating from filing return till assessment. Though penalty order was in 2002, appellant did not file compounding application even after that date or before conviction in 2019, dragging issue for 20 years. Default termed wilful. Circular No.25/2019 did not intend to extend compounding benefit to all who applied by 31.12.2019. Rejection of compounding application upheld as appellant's application was belated and no scope for compounding after conviction under direct tax laws. Paying tax, penalty and interest does not entitle compounding. Authorities rightly rejected compounding application.....